request for approval of neighborhood resident housing ...€¦ · hcd-funded developments will...

Request for Approval of Neighborhood Resident Housing Preference

by the California Department of Housing and Community Development

1

Mayor’s Office of Housing and Community DevelopmentCity and County of San Francisco

Overview• Low-income households continue to

experience displacement pressure• Neighborhood preference improves

neighborhood resident occupancy take-up• Application of neighborhood preference to

HCD-funded developments will improve the transparency of housing lotteries and enhance income equity• No disparate impact• Consistent with Uniform Multifamily

Regulations

Mayor’s Office of Housing and Community Development 2

Median RentFrom 2010 to 2018, median rent in San Francisco increased 9%

Severe Rent Burden20% of San Francisco households are severely rent burdened

EvictionsFrom 2010 to 2016, the number of evictions notices filed with the Rent Board increased by 56%

Policy Background• Passed by the Board and signed in to

law by Mayor Ed Lee in 2015• Provides a lottery preference up to

40% for residents living within the same supervisor district or within ½ from the site of the development• First implemented in July 2016 at

Richardson Hall (LGBTQ Seniors)• Applied to 31 total developments

Neighborhood Resident Housing Preference (NRHP) is one policy tool that the City uses to address displacement of low-income households


Completed Developments with NRHP31 total projects with 629 units have marketed since July 2016

Pipeline Developments There are 33 developments with NRHP in the pipeline with a estimated completion by June 30, 2023

Pipeline Developments An additional nine developments without NRHP are in the pipeline

Disparate Impact Analysis


•Model assessed disparate impact using two court-informed test • Four-fifths test*

(Langlois v. Abington Housing Authority, and EEOC)

• Standard deviation analysis (Castenada v. Partida)

•Model used 2016 ACS household income data to estimate income-eligible applicants and occupants.• Applied to multiple geographies

Initial Model


Disparate Impact AnalysisInitial Model Results


Four-Fifth Test Analysis

A selection rate less than four-fifths will generally be regarded as evidence of adverse impact.

Number of rates below 80% 1% of rates below 80% 2%

Supervisorial District White Black Asian Other HispanicDistrict 1 96% 95% − 96% 94%District 2 − 96% 96% 87% 92%District 3 88% − 92% 80% 87%District 4 96% 96% − 91% 94%District 5 − 88% 83% 79% 81%District 6 − 89% 90% 88% 89%District 7 92% − 91% 91% 89%District 8 99% − 94% 90% 95%District 9 90% 98% 92% 96%District 10 85% − 89% 91% 86%District 11 93% 97% − 95% 97%

Test assesses whether a selection rate for a minority race/ethnic group is less than four-fifths (80%) of the rate for the largest race/ethnic group.

Disparate Impact AnalysisInitial Model Results


Standard Deviation Analysis (Z-Test)

Results greater than two to three standard deviations indicate a possible selection bias.

Number of deviations greater than 3 0% of deviations greater than 3 0%

Supervisorial District White Black Asian Other HispanicDistrict 1 0.21 -0.42 0.88 -0.32 -0.54District 2 1.65 -0.42 -0.66 -0.64 -0.54District 3 0.00 0.00 1.98 -0.64 -0.54District 4 0.00 -0.42 1.10 -0.52 -0.54District 5 0.83 1.67 -0.88 -0.64 -0.54District 6 -0.21 0.42 0.11 0.00 0.00District 7 0.41 0.00 0.00 -0.32 -0.27District 8 1.03 0.00 -0.66 -0.32 -0.27District 9 -1.08 -0.03 -0.69 0.94 1.63District 10 -1.24 1.67 0.00 0.64 0.27District 11 -1.42 0.00 0.66 0.32 0.54

Test measures the mathematical probability of a nonbiased selection system by statistically evaluating the difference between observed and expected values.


• Model evaluated a statistically significant number of sample lotteries using actual applicant data (n=30)

• Applicant data from low-income rental projects for applicability to state-funded multifamily projects

• Randomly selected applicant data from a pool of 5 rental projects in District 10

• Random.org used to select estimated lottery winners

Second Model


Disparate Impact AnalysisSecond Model


Four-Fifth Test Analysis (EEOC Guidelines)Applicants

(Black)Occupants

(Black)Selection

Rates (Black)Applicants

(Asian)Occupants

(Asian)Selection

Rates (Asian)Four-Fifths Test (>80%)

9,883 72 0.73% 29,060 192 0.66% 91%

Applicants (Black)

Occupants (Black)

Selection Rates (Black)

Applicants (Latino)

Occupants (Latino)

Selection Rates (Latino)

Four-Fifths Test (>80%)

9,883 72 0.73% 19,619 134 0.68% 94%

Applicants (Black)

Occupants (Black)


Applicants (Latino)

Occupants (Latino)

Selection Rates (Latino)


9,883 72 0.73% 7,376 52 0.71% 94%

Applicants (Black)

Occupants (Black)


Applicants (White)

Occupants (White)

Selection Rates (White)


9,883 72 0.73% 6,196 40 0.65% 89%

Standard Deviation Analysis (Z-Test)Asian BlackHispanic/Latino White Other Unknown

Occupancy w/o Neighborhood Preference 197 67 133 42 50 103Standard Deviation 7.90 5.99 7.90 8.92 4.86 7.17Occupancy w/ Neighborhood Preference 192 72 134 40 52 102z-score -0.63 0.83 0.13 -0.22 0.41 -0.14

Conclusions• A 25% neighborhood preference does not

result in disparate impact• Consistent with Uniform Multifamily

Regulations• Neighborhood preference improves

neighborhood resident occupancy take-up (150%)• Applying NRHP to HCD-funded

developments at 25% will improve transparency of housing lotteries and enhance income equity


Next Steps• Eddy & Taylor Family Apartments

(December 2018)

• 455 Fell Street (January 2019)Upcoming Projects


Eddy & Taylor Family ApartmentsEddy & Taylor Family Apartments

request for approval of neighborhood resident housing ...€¦ · hcd-funded developments will...

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